ML18023A670

Comment (28) of Jody Gibson & Donna Gilmore on Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities

ML18023A670
Person / Time
Site:	San Onofre
Issue date:	01/02/2018
From:	Gibson J, Gilmore D San Onofre Safety
To:	Rules, Announcements, and Directives Branch
References
82FR52944 00028, NRC-2017-0211
Download: ML18023A670 (2)

Text

PUBLIC SUBMISSION Docket: NRC-2017-0211 As of: 1/8/18 4:25 PM Received:

January 02, 2018 Status: Pending_Post Page 1 of2 Tracking No. lk2-90pd-c5yj Comments Due: January 02, 2018 Submission Type: Web Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities Comment On: NRC-2017-0211-0001 Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities; Request for Comment on Draft NUREG Document:

NRC-2017-0211-DRAFT-0029 Comment on FR Doc# 2017-24734

@ Name: Jody Gibson Address: Submitter Information

'if~ r-,R. 5z'i~t./ 11/1.s /2017 317 E. Wall Ave. Des Moines, IA, 50315 Email: jodyg8@msn.com SUNSI Review Complete Template = ADM -013 E-RIDS= ADM-03 Add= Je.rvi ey 5"" ~-1-h (_ j us SJ General Comment The NRC cannot meet its mission to "ensure adequate protection of public health and safety and the environment" if it continues to allow thin-wall welded canisters they admit are vulnerable to cracks, that cannot be fully inspected (inside or out), and cannot be repaired, maintained and monitored to prevent (not just detect) radiological leaks. There is no adequate or proven detailed plan required to address major radiological leaks, or to address on-site replacement of containers.

Seismic requirements for partial cracks is not addressed.

See below webpage for details on the Holtec UMAX System planned for San Onofre and why this is an example of a system with major problems that should not be approved.

https://sanonofresafety.org/holtec-hi-storm-umax-nuclear-waste-dry-storage-system/

Each canister contains about as much or more lethal Cesium-137 as released from the 1986 Chernobyl nuclear disaster, yet the NRC knows the boron metal in the canisters will not https://www.fdms.gov/fdms/getcontent?objectld=0900006482d8fb13&format=xml&showorig=fa1se 01/08/2018 Page 2 of2 prevent the fuel from going critical if exposed to non-borated water from through wall cracks (in storage or transport).

NUREG-2215 states it requires !'conservative assumptions", "inspections", and admits to many "unknowns".

NUREG-2215 is not "conservati_ve", does not require adequate "inspections", and does not resolve the many "unknowns" that would be eliminated if the NRC mandated and enforced critical safety requirements to inspect, monitor, maintain and repair (both inside and out) to PREVENT leaks. Proven dry storage technology exists that meets critical basic safety requirements we expect in a car. Does the NRC consider thin-wall canisters "conservative assumptions" compared to thick-wall casks? If so, why? Why does the NRC allow containers that do not meet these basic critical safety requirements?

Respectfully,.

Donna Gilmore, SanOnofreSafety.org donnagilmore@gmail.com 949-204-7794 Basic Safety Requirements Thin-wall canisters Thick-wall casks . Thick walls No. Only 1/2 to 518th of an inch Yes. 10 to 19.75 inches Won't crack. No Yes Ability to inspect inside & out, maintain, repair (fuel baskets, other parts) No Yes Monitor to fix problems before leaks No Yes ASME container certification No Yes Defense in depth (redundancy)

No Yes Stored in concrete building No Yes Gamma & neutron protection Requires vented concrete overpack Yes Transportable No transport with cracks. 10 CFR 71.85 Yes Proven technology No. Conditions unknown. Most in use less than 15 yrs, a few 30 yrs. Yes. Inspected and used over 40 years https://www.fdms.gov/fdms/getcontent?objectld=0900006482d8fb13&format=xml&showorig=false 01/08/2018